ADA submitted a response to Defra’s ELM (Environmental Land Management) policy consultation on Friday 31st August. Thank you to ADA members who submitted points for inclusion.
DEFRA’s “ELM Policy Discussion Document” had been issued earlier in the year with a call for responses from “farmers, foresters and land managers”. The document set out the proposed scheme design and requested feedback on particular elements such as structure, design principles and objectives and then more detailed suggestions for payment methods and calculations, the types of activity the scheme should cover and the provision and benefits of advice and guidance. The document also provided an overview of the tests and trails currently underway which are testing specific elements and delivery methods and the National Pilot planned to begin in late 2021.
The proposed ELM scheme sets out a structure of three tiers, aimed at delivering “public goods for public money”, or more specifically, funding for farmers and land managers to deliver environmental improvements in line with the goals of the 25 Year Environment Plan. The proposed delineation between the tiers appears to be the spatial scales at which the environmental improvements are applied and the types of land managers which can be involved in each tier, from a farmer on a field and farm scale in tier one to a collaboration of Land Managers on a large landscape scale in tier 3. Much of what is proposed is a hybrid of the most successful elements of previous agri-environment schemes but there are new concepts which are being explored such as payment for results rather than actions, devolution of responsibility to decide area priorities and the wider provision of advice and guidance.
ADA’s responses to the consultation naturally focused on how the proposed elements of ELM could better contribute to the wider aims and objectives of water-level and resource management. We made it clear that we consider water-level and resource management to be one of the best examples of providing “public goods for public money” there is and gave many examples where this has been demonstrated. We stressed that water-level and resource management should be made a priority in all farming and environmental policy and strategies considering the criticality of water to each. We also urged the Government to better align its policies and strategies, particularly the recently published National Flood & Coastal Erosion Risk Managent (FCERM) Strategy, and the Government’s Farming for the Future policy if the goals of both and the 25 Year Environment Plan are to be achieved.
Our position was clear that the unfunded flood alleviation service which many farmers have provided to date, either deliberately or not, cannot continue to go unrewarded or undervalued. We set out detailed examples of when farmland inundation could be successfully controlled and rewarded through the scheme and highlighted that Risk Management Authorities (RMAs), such as local IDBs, are well placed with their local knowledge and practical expertise to assist in with designing and delivering such measures.
Strong recommendations were made for ELM activity to be multi-functional where possible and to focus on delivering long-term environmental improvements relating to water-level management which are resilient to the weather extremes we are to expect from climate change. But we also suggested that simple activities which could deliver catchment-scale improvements in water-level management, such as improved soil management, should be made mandatory.
What remains unclear at this stage is to what extent public authorities, are going to be able to participate in ELMS. In particular, we requested clarity around the eligibility of IDBs to apply for ELM funding and the opportunities for RMAs such as IDBs to be involved in the advice and guidance provision. We look forward to learning more from DEFRA’s response to the consultation, expected in autumn this year.